Wilson Creek Gas Plant - Executive Summary |
|
Risk Management Plan Wilson Creek Gas Plant NGL Storage Facility Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Wilson Creek Gas Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by our efforts in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, facility trained personnel will evaluate the situation, take actions within the capabilities of the facility, and/or notify the necessary outside agencies DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Wilson Creek Gas Plant, located in Rio Blanco County, Colorado, operates a variety of processes to produce a petroleum product called NGL from natural gas. The Wilson Creek Gas Plant NGL storage site has regulated flammables, including propane, butane and pentane. OFFSITE CONSEQUENCE ANALYSIS RESULTS The worst-case scenario (WCS) associated with a release of the NGL product at the Wilson Creek Gas Plant is a vapor cloud explosion (VCE) involving the largest inventory of NGL. contained in a single vessel/storage tank. A written procedure is in place to limit the maximum inventory in this vessel/storage tank to 310,000 lbs. (85% of the maximum capacity). The entire inventory is assumed to release and ignite, resulting in a VCE. Results of this analysis indicate that this release from the facility does not affect offsite receptors. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this WCS. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the Wilson Creek Gas Plant . The Wilson Creek Gas Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in 'Operator Rounds' sheet. The facility maintains the process within these limits by using process controls and monitoring instruments, trained personnel, and protective instrument systems (e.g., automated shutdown systems. The facility also has access to technical documents that provide information about the design and construction of process equipment. This information includes m aterials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with procedures and equipment operating history, provides a basis for inspection and maintenance activities, as well as for evaluating proposed process and facility changes so safety features in the process are not compromised. Contractors The Wilson Creek Gas Plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform facility personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the Wilson Creek Gas Plant evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contractor performance with regard to their safety obligations. Safe Work Practices The Wilson Creek Gas Plant has long-standing safe work practices in place to help provide worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to isolate energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to verify that ade quate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help perform operations and maintenance activities safely. Incident Investigation The Wilson Creek Gas Plant promptly investigates all incidents related to a covered process that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to facility management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation i s documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help determine that the accident prevention program is functioning properly, the Wilson Creek Gas Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate in these audits. The audit team develops findings that are forwarded to facility management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. CHEMICAL-SPE CIFIC PREVENTION STEPS The processes at the Wilson Creek Gas Plant have hazards that must be managed for continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program summarized previously is applied to all RMP-covered processes at the Wilson Creek Gas Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The Wilson Creek Gas Plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes: Release Detection 1.Hydrocarbon detectors with alarms. Release Containment/Control 1. Proce ss relief valves that discharge to a flare to capture and incinerate episodic releases 2. Valves to permit isolation of the process (manual or automated) 3. Automated shutdown systems for specific process parameters (e.g., high temperature) 4. Curbing or diking to contain liquid releases 5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 6. Atmospheric relief devices. FIVE-YEAR ACCIDENT HISTORY The Wilson Creek Gas Plant has an excellent record of accident prevention over the past 5 years. EMERGENCY RESPONSE PROGRAM INFORMATION The Wilson Creek Gas Plant maintains a written emergency action plan, which is in place to help protect worker and public safety as well as the environment. The plan identifies steps to be taken in case of an accidental release including: proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuatio n, notification of local emergency response agencies and the public if a release occurs. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency duties. The emergency action plan is updated when necessary based on modifications made to processes or other Wilson Creek Gas Plant facilities. PLANNED CHANGES TO IMPROVE SAFETY The Wilson Creek Gas Plant resolves findings from PHAs, some of which result in modifications to the process. The following types of changes are expected over the next few years in response to safety audits, and incident investigation findings: For example - 7 Identify several items expected to improve as results on audits or incident investigations. |